Privacy Policy

FinPal Services Inc dba FinStackk (“we,” “us,” and “our”) takes the private nature of your personal information seriously. This policy regarding our privacy practices (the “Policy”) describes how we treat the information we collect when you use our services (including the Site, collectively, the “FinStackk Services”).

This Policy describes the types of information we may collect from you or that you may provide when you access or use the Site and the FinStackk Services or other features, functions, services, products, and our practices for collecting, using, maintaining, protecting, and disclosing that information. When you visit or use the Site and the FinStackk Services, you are consenting to our practices in this Policy. Please read it carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with this Policy and practices, your only choice is not to use any of our Services.

This Policy is subject to and made a part of our Terms of Service, including as applicable its requirement to arbitrate disputes and liability limits. Capitalized terms not defined in this Policy shall have the meanings given to them in the Terms of Service.

Policy does not apply to information collected by:

- Us offline or through any other means, including on any other website operated by us or any third party; or
- Any third party, including through any application or content (including advertising) that may be accessible from or on the Site or any of the FinStackk Services.

Minors under the Age of 18

None of the Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site or the FinStackk Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of the Services or any of its features or register or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at ____________.

Information We Collect About You and How We Collect It

We collect or may collect several types of information from and about you and other users of the Services, including:

• Information by which you may be personally identified, such as name, e-mail address, and the name of the company at which you work (“personal information”).
• Accounting and financial information through the accounting files that you connect with us (e.g., Xero, QuickBooks Online, etc.) and/or the financial accounts you give us access to.
• Financial and billing information.
• Analytics information.
• Information that is about you but individually does not identify you, such as IP address and date and time of visit.
• Information from your device, including contact information.
• Usage details and information, including how you communicate with other users of the Services, such as the time, date, sender, and your interactions with messages (such as when you open a message or capture a screenshot).
• Device, internet, and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number).
• Location information when you use the Site or FinStackk Services.
• Information that you provide by registering or filling in forms or applications on or through the Site or in connection with the engagement agreement, including in connection with registering to access and use the Services.
• When you report a problem with the Site or any of the FinStackk Services.
• Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or
• Details of transactions you carry out through the Site and any of the FinStackk Services.

The FinStackk Services permits customers to share and manage information by uploading and submitting data or content that can be shared, stored, and accessed through the FinStackk Services (“Customer Data”). If that Customer Data includes personal information, we process any personal information contained in such Customer Data in the role of a processor on behalf of a customer (and/or its affiliates) who is the controller of the personal information. This Policy does not cover Customer Data, including any personal information contained in it. Customers control the nature of Customer Data and are the data controllers and are required to provide all necessary notices and obtain all necessary consent from any individual. We are a data processor of such Customer Data, which means we only use it as directed by our customers.

We collect this information:

• Directly from you when you provide it to us.
• From your third-party accounts (such as bank accounts, QuickBooks accounts, and billing and invoicing accounts) that you enable us to access through your Login Credentials.
• Automatically as you navigate through or use the Site and the FinStackk Services through the use of cookies and tracking technologies; and
• From third parties, such as our business partners and other third parties, including Service Providers as discussed below, that provide us or you with certain services.

Certain web transactions may also involve your calling or emailing us or our emailing or calling you. Please be aware that we may monitor and, in some cases, record such calls for staff training or quality assurance purposes.

Service Providers

We may use or partner with other third-party companies, agents, or contractors for various purposes in connection with our business and operations (“Service Providers”), including billing and payments, error tracking, relationship building, the marketing and growth of our business, and the performance of services on our behalf, such as gathering and analyzing information and the provision of FinStackk Services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Service Providers in order to enable them to perform these responsibilities and to provide these services.

Many Service Providers have adopted their own privacy policies, which are not subject to control by us. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect, and disclose your information.

The Service Providers may also transmit cookies to your computer or device, when you click on ads that appear on or through the FinStackk Services. Also, if you click on a link to a third-party website, such third party may also transmit cookies to you. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any of the FinStackk Services, and those third parties may not honor “Do Not Track” requests that you have set using your web browser.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you the FinStackk Services and the content and the other products and services that you request from us.
• To provide the Site and its contents to you.
• To process and complete transactions and send you related information, including the request for and the provision of the FinStackk Services.
• To provide technical and other support to you.
• To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, our customers, and our select partners.
• To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including for billing and collection.
• To notify you about changes to the Site and the FinStackk Services.
• To enhance the safety and security of all of the FinStackk Services.
• To verify your identity and prevent fraud or other unauthorized or illegal activity.
• To enable marketing, remarketing, and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third-party websites.
• To perform targeted and other advertising on our websites and third-party websites.
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

Some of the information that we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties, or you provide to us. It helps us to improve the Site and the FinStackk Services, and to deliver a better and more personalized service, including enabling us to:

• Estimate our audience size and better understand usage patterns.
• Store information about your preferences, enabling us to customize the Site according to your individual interests.
• Speed up your searches; and
• Recognize you when you return to the Site.

Disclosure of your information.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this Policy:

• To our subsidiaries and affiliates.
• To other users in your organization in connection with any of the FinStackk Services.
• To Service Providers, contractors, and other third parties we use to support our business, including credit card payment processors, error tracking, and marketing support.
• To a potential or actual buyer, assignee, or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about you and other users of the Site and the FinStackk Services is among the assets that may be or are actually transferred;
• To fulfil the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request; and
• To enforce or apply the engagement agreement and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

Use of Cookies and Other Tracking Technologies

The technologies we use for automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.
• Web Beacons. Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We honor web browser “Do Not Track” signals and other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third- party websites or online services.

Information Choices and Changes

We offer the following ways for you and users to manage our use of their personal information:

Tracking Technologies and Advertising.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that all or some parts of the Services may then be inaccessible or not function properly.

Email Communications.

• Administrative Emails. As part of the Services, we may occasionally send you email and other communications, such as administrative communications relating to your Account (e.g., for password resets). These communications are part of the Services, and you may not be able to opt out of receiving them as long as you are using the Services.
• Marketing Emails. We may occasionally send you marketing materials, newsletters, or other similar emails. If you do not wish to have your e-mail address used by us to promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email.
• Phishing Attacks. We will never email you to ask for your password or other account information. If you receive such an email, please forward it to us at connect@finstackk.com.

Advertising.

We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: finstackk.com

Access, Copy and Corrections.

You may access, obtain a copy of, review, and correct certain elements of your personal information by logging into the settings area of the portal. You may also submit such requests to us by email to connect@finstackk.com. You may also request deletion of your personal information; we will honor such requests to the extent required by law, provided that we may retain Customer Data, including personal information, under the Terms of Service or if required to comply with law, legal process, or legal obligations.

Storage, Retention and Transfer of Your Information

We may store any information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our affiliates, agents, or Service Providers. If you access or use the Site or any of the FinStackk Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by us and you. By allowing us to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

Although users from all over the world may access the Site and the FinStackk Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countrieswhose data-protection and privacy laws may offer fewer protections than those in your home country.

Contact Information

We welcome your comments or questions about this Policy. You may contact us at 276-221- 0992 or at our address:

FinPal Services Inc, 20745, Williamsport Pl, Suite #200, Ashburn, VA 20147.

Use of Google Analytics, AdWords, and Other Similar Services

The Services may use Google Analytics, New Relic, and Google AdWords and other similar services. Service Providers, including Google, use cookies to serve ads based on someone’s past visits to the Site. Of course, any data collected will be used in accordance with this Policy, Google’s or New Relic’s privacy policy or the privacy policy of the FinStackk Services used by us.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

DoubleClick: We may use Google Analytics remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future, you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.

Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.

Data Security

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective, and we cannot ensure or warrant the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Services.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to and use of certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas about any of the Services.

Data Breach Notification

In the event of a data breach involving personal information, FinStackk will take steps to notify affected individuals as required by applicable law. FinStackk will investigate any suspected or actual data breach and will take reasonable measures to mitigate the potential harm and prevent any future breaches. FinStackk will also take steps to identify and address the cause of the breach and will work with any applicable law enforcement or regulatory authorities as required. If you have reason to believe that your personal information has been compromised as a result of a breach, please contact us immediately at connect@finstackk.com.

GDPR Compliance

FinStackk is committed to complying with the General Data Protection Regulation (“GDPR”), which is a European Union regulation that sets out the rules for how personal data must be collected, processed, and stored. If you are a user located in the European Union, you have certain rights under the GDPR, including the right to:

• Access your personal data that we hold.
• Rectify inaccuracies in your personal data.
• Erase your personal data.
• Object to the processing of your personal data.
• Restrict the processing of your personal data.
• Receive your personal data in a portable format.
• Withdraw your consent to the processing of your personal data.

If you wish to exercise any of these rights, please contact us at connect@finstackk.com. We will respond to your request within the timeframes required by the GDPR.

Changes to our Privacy Policy

It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal information that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and if required by law, to attempt to get your consent to the changes. The date the Policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this Policy to check for any changes. Like our Terms of Service, of which this Policy is a part, your use, and/or continued use after our efforts to contact you, of the Site or any of the FinStackk Services, means that you agree to be bound by such changes.

Survival

The policies indicated in this Policy will remain effective, even if the agreements between us are terminated and you are no longer using any of the Services.